ASN Report 2017

134 ASN report on the state of nuclear safety and radiation protection in France in 2017 Chapter 04  - Regulation of nuclear activities and exposure to ionising radiation 3.1.2 Inspection resources implemented To ensure greater efficiency, ASN action is organised on the following basis: ཛྷ ཛྷ inspections, at a predetermined frequency, of the nuclear activities and topics of particular health and environmental significance; ཛྷ ཛྷ inspections on a representative sample of other nuclear activities; ཛྷ ཛྷ technical inspections of approved organisations. The inspections may be unannounced or notified to the licensee a few weeks before the visit. They take place mainly on the site or during the course of the relevant activities (work, transport operation). They may also concern the head office departments or design and engineering departments at the major licensees, the workshops or engineering offices of the subcontractors, the construction sites, plants or workshops manufacturing the various safety-related components. ASN uses various types of inspections: ཛྷ ཛྷ standard inspections; ཛྷ ཛྷ reinforced inspections, which consist in conducting an in-depth examination of a targeted topic by a larger team of inspectors than for a routine inspection; ཛྷ ཛྷ in-depth inspections, which take place over several days, concern a number of topics and involve about ten or so inspectors. Their purpose is to carry out detailed examinations and they are overseen by senior inspectors; ཛྷ ཛྷ inspections with sampling and measurements. With regard to both discharges and the environment of the facilities, these are designed to check samples that are independent of those taken by the licensee; ཛྷ ཛྷ event-based inspections carried out further to a particularly significant event; ཛྷ ཛྷ worksite inspections, ensuring a significant ASN presence on the sites on the occasion of reactor outages or particular work, especially in the construction or decommissioning phases; ཛྷ ཛྷ inspection campaigns, grouping inspections performed on a large numbers of similar installations, following a predetermined template. Labour inspectorate duties in NPPs lead to various types of interventions 2 , focusing in particular on: ཛྷ ཛྷ checking application of the Labour Code by EDF and outside contractors in the NPPs (verification operations that include inspections); ཛྷ ཛྷ participation in meetings of the CHSCT, CIESCT and inter- firm Health, Safety and Working Conditions Committee (EPR construction site); ཛྷ ཛྷ performance of inquiries further to requests, complaints or information, after which the inspectors can issue resolutions. ASN sends the licensee an inspection follow-up letter officially documenting: ཛྷ ཛྷ deviations between the situation observed during the inspection and the regulations or documents produced by the licensee pursuant to the regulations; ཛྷ ཛྷ anomalies or aspects warranting additional justifications; 2 . The intervention is the representative unit of activity normally used by the labour inspectorate. ཛྷ ཛྷ best practices or practices to which improvements could be made, even if not directly constituting requirements. Some inspections are carried out with the support of an IRSN representative specialised in the facility checked or the topic of the inspection. ASN inspectors ASN has inspectors designated and accredited by its Chairman, in accordance with the conditions defined by Decree 2007- 831 of 11th May 2007 setting the procedures for appointing and accrediting nuclear safety inspectors, subject to their having acquired the requisite legal and technical skills through professional experience, mentoring or training courses. The inspectors take an oath and are bound by professional secrecy. They exercise their inspection activity under the authority of the ASN Director-General and benefit from regularly updated practical aids (inspection guides, decision aids) to assist them in their inspections. As part of its continuous improvement policy, ASN encourages the exchange and integration of best practices used by other inspection organisations: ཛྷ ཛྷ by organising international exchanges of inspectors between Safety Authorities, either for the duration of one inspection or for longer periods that could extend to a secondment of up to several years. Thus, after having observed its advantages, ASN has adopted the concept of in-depth inspections described earlier. However, it did not opt for the system involving a resident inspector on a nuclear site, as ASN considers that its inspectors must work within a structure large enough to allow experience to be shared and that they must take part in checks on different licensees and facilities in order to acquire a broader view of this field of activity. This choice also allows greater clarity in the exercise of the respective responsibilities of the licensee and the inspector; ཛྷ ཛྷ by taking on inspectors trained in other inspection practices. ASN encourages the integration into its departments of inspectors from other regulatory authorities, such as the Regional Directorate for the Environment, Planning and Housing, ANSM, Regional Health Agencies (ARS), etc. It also proposes organising joint inspections with these authorities concerning the activities within their joint field of competence; ཛྷ ཛྷ by encouraging its staff to take part in inspections on subjects in different regions and domains, notably to ensure the uniformity of its practices. Table 3 presents the headcount of inspectors as at 31st December 2017. Some inspectors operate in several inspection areas, and all the operational entity heads and their deputies fulfil both managerial and inspection functions. Most of the inspections are carried out by inspectors assigned to the regional divisions, who represent 51% of the ASN inspectors. The 152 inspectors assigned to the departments take part in ASN inspections within their field of competence; they represent 49% of the inspector headcount and performed 17% of the inspections in 2017. In 2017, 1,751 inspections were carried out, including 635 in the BNIs, 94 in activities linked to Pressure Equipment,